Last week, EPA Administrator Andrew Wheeler talked to Congress. Members had questions about his recent changes to the National Ambient Air Quality Standards updates for particulate matter and ozone. Wheeler’s comments last week and earlier make clear that he either doesn’t understand or isn’t being honest about how the EPA is proceeding as it sets health-protective air pollution standards. Here’s the reality around three points that Administrator Wheeler isn’t clear on.
1. CASAC doesn’t have the expertise it needs
The Clean Air Scientific Advisory Committee (CASAC) concluded at its most recent meeting that it does NOT have the expertise needed to adequately provide science advice to the EPA on development of the particulate matter standard. The committee’s conclusion directly conflicts with Administrator Wheeler’s comments on the hill this week after the CASAC meeting. Rather than listen to CASAC’s conclusion that it does not have the expertise, Wheeler doubled down on his earlier comments to Congress in insisting the committee has “a very good balance of talents.” It seems someone should give Wheeler the notes from EPA’s own committee’s meeting. Instead of denying this need for additional expertise, Wheeler could and should reconvene the particulate matter review panel that he disbanded last October.
The administrator also appeared confused about what expertise does exist on CASAC. When asked about epidemiologic expertise on the committee, he said, “I believe one person had to resign who I believe was an epidemiologist who we — we weren’t able or we — we haven’t yet replaced that person, if I’m remembering the right board. It was either the Science Advisory Board or the CASAC.” Since the administration appointed new CASAC members last October, there has not been an epidemiologist on the committee—a huge gap given how central epidemiologic evidence is to assessing the health outcomes of ambient air pollutant exposure. Given this shortcoming, on top of the lack of pollutant review panels, it is no wonder that CASAC itself recognizes its need for more expertise on its teleconference two weeks ago.
2. Pollutant review panels don’t slow down the process
In his comments to Congress, Wheeler said that the particulate matter review panel was disbanded because pollutant review panels were slowing down the process of reviewing ambient air pollution standard. “We took a hard look at what was causing the delay because the agency had never met the five-year timeframe for ozone or PM,” he told the Senate Appropriations Committee. This is objectively false and runs counter to Wheeler’s previous statements where he insisted that the panels were unnecessary. The process of ensuring a robust scientific review of air pollution standards is of course not the fastest process in the world. Just as the peer-review process tends to be slow, so too is review of thousands of pages characterizing the state of the science on a pollutant and its health and welfare effects by a group of the top experts in the field. But the pollutant review panels simply augment the expertise of CASAC. The panel’s review of the documents happens in the very same meetings that CASAC already has, and must have, according to Federal Advisory Committee Act rules. Sure, the additional experts in the room from inclusion of the panel might mean longer discussions, or an extra conference call, but this is far from a huge slow down on the process. Instead, a bigger reason that ambient air quality standard updates aren’t speedy is because of the limited capacity on the EPA side. If the agency were given more resources to conduct and prioritize reviews, this could speed up the process—if this were, in fact, the goal of this Administration.
Wheeler claims to be concerned about whether or not the review happens within the Clean Air Act mandated five-year window. It is true that reviews are often not completed within five years, but the courts have generally recognized the need for thorough scientific reviews in standard updates. Instead, the administration is insisting that both the particulate matter and ozone reviews happen by the end of 2020.
3. Science advisors should be chosen based on diversity of expertise not geography
In his testimony, Wheeler asserted that “CASAC members and the members of the Science Advisory Board were selected in large part for geographic diversity, geographic diversity of — of — of viewpoints and backgrounds.” This one should be intuitive. If you took a chemistry class in Cleveland, you probably learned the same thing as a chemistry student in Miami. There is, of course, no reason geography should matter when it comes to understanding of science. Universities, academic journals, and scientific conferences don’t curate activities through a geography lens, and neither should the EPA. Instead what the EPA should do, and always has done, is select members of scientific advisory committees for diversity of expertise. To get the best science advice, the agency should make sure the committee includes experts in diverse areas. For CASAC, that means including experts in atmospheric science, medicine, toxicology, epidemiology, etc. Yet, the current CASAC excludes key areas of expertise like epidemiology.
Wheeler blames the selection of CASAC members on EPA staff saying he, in fact, did not pick the members, EPA staff did. He told Congress last week, “I didn’t hand-select any of the people on the CASAC. They were recommended to me … by the career staff and … and the Science Advisory Board Office.” This is curious given that it is the EPA administrator who decides committee membership. EPA staff always make recommendations to the administrator for who would be good candidates for a committee, given balance of expertise, but there has never been a committee like this, with so little membership from active researchers in the field and instead heavily weighted toward regulators. It is hard to imagine that EPA staff would select such a committee without input from political level staff.
Sacrificing both quality and speed
Wheeler’s need for speed has not yielded results. Thus far, the PM review has not been faster than recent reviews that included the review panel. Currently, CASAC is finalizing its letter to the EPA recommending how the agency should revise its science assessment on particulate matter. This letter will confirm that the committee agrees it doesn’t have the needed expertise and make specific recommendations to EPA staff on the document. The EPA can then move forward without the expert advice its science advisors say it needs, or it can delay the process and reconvene the robust particulate matter review panel necessary for a science-informed process.
As of now, Administrator Wheeler is getting neither speed nor quality out of its particulate matter review. It is looking more and more like he won’t get what he wants out of the particulate matter standard update. But if the EPA fails to set a PM standard based on science, the public won’t either.
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